Why I’m voting against I-522
If you don’t live in Washington state, you might be unaware of this year’s controversial ballot initiative, I-522. In short, it’s a law which proposes that some foods deemed as “genetically engineered” or containing “genetically modified organisms” must be labeled as such in grocery stores.
I first became aware of this initiative two or three months ago via a sign posted at my local PCC where I buy most of my groceries. It was endorsing the initiative. My first thought was, “Oh, I haven’t heard about a battle over genetically engineered/modified foods, but if there is one, labeling seems like it could be a reasonable compromise.” A moment later though, I thought, “What do they mean by genetically engineered? I hope the actual initiative is very specific about what’s labeled and why! It would be silly if every edible banana needed a label just because edible bananas don’t exist in nature.”
That was about the end of my thinking on the subject for quite a while. Then a month or so ago I began hearing more discussion about it, and seeing a lot of propaganda – all in support of the initiative. And all sponsored by PCC or Whole Foods. Finally, I saw an emotionally charged tweet with the hashtag #LabelGMOs and I replied to inquire why the tweeter considered this to be an important issue.
I decided to do some research to learn about the nature of the initiative and the facts and arguments applicable to the discussion. At first blush, I was unable to find anything to support the initiative. Well, nothing other than myths and emotional diatribes from non-experts with no sources to back up any of some fairly outlandish claims. On the opposing side I immediately found well-stated, sourced, logical objections from well-respected groups such as the American Association for the Advancement of Science who say, “Legally Mandating GM Food Labels Could ‘Mislead and Falsely Alarm Consumers’,” and the American Medical Association (PDF).
The AMA report’s conclusion is:
Despite strong consumer interest in mandatory labeling of bioengineered foods, the FDA’s science-based labeling policies do not support special labeling without evidence of material differences between bioengineered foods and their traditional counterparts. The Council supports this science-based approach, and believes that thorough pre-market safety assessment and the FDA’s requirement that any material difference between bioengineered foods and their traditional counterparts be disclosed in labeling, are effective in ensuring the safety of bioengineered food. To better characterize the potential harms of bioengineered foods, the Council believes that per- market safety assessment should shift from a voluntary notification process to a mandatory requirement. The Council notes that consumers wishing to choose foods without bioengineered ingredients may do so by purchasing those that are labeled “USDA Organic.”
Someone supporting the initiative then sent me a link to the World Health Organization’s FAQ on the issue, apparently without reading it. It echoes the sentiments of the AAAS and AMA. As do the European equivalents of these organizations, such as the OECD and EFSA. So what gives?
My next step was to look at the text of the initiative itself. Oddly enough, it seems many of the big sites promoting I-522 have links to read the text which are broken. Fortunately you can get the full thing from the WA Secretary of State site in PDF form here. As I read the text I was overwhelmed with incredulity, and here’s why:
1) It provides no context for its definition of “genetic engineering”
522 immediately begins throwing around the phrase “genetic engineering” with absolutely no effort to establish the scope of its meaning. As any biologist will tell you, generic engineering is not new and can be accomplished through a variety of means going back thousands of years. The earliest banana cultivars are believed to have been created between 5000 and 8000 BCE. The bananas and many other plants you and I eat today are hybrids which are initially sterile and then made fertile using polyploidization. Neat stuff, but not newsworthy.
Of course, most anti-GMO advocates will immediately cry that GE techniques like hybridization and artificial selection are not covered by their definition of “genetically engineered” or “genetic modification.” But the fact that the initiative makes countless claims using this term before making any effort to establish what it applies to is incredibly disconcerting.
Later, 522 establishes a definition of “genetically engineered” that is more specific. However, it gives no context regarding other forms of genetic engineering that exist, nor does it provide any basis for choosing the particular scope it has selected.
2) It cites no sources.
The initiative says:
Polls consistently show that the vast majority of the public, typically more than ninety percent, wants to know if their food was produced using genetic engineering.
Which polls? What question was actually asked and which options were given as answers? Why is this an argument for labeling? Everyone knows you can get ridiculous poll results by asking biased and uneducated groups questions which they’re ill-equipped to answer. Keep in mind that many polls also show nearly 90% of Americans don’t “believe in” evolution. You know, the thing that makes genetic engineering possible.
It also says:
United States government scientists have stated that the artificial insertion of genetic material into plants, a technique unique to genetic engineering, can cause a variety of significant problems with plant foods. Such genetic engineering can increase the levels of known toxicants in foods and introduce new toxicants and health concerns.”
Which scientists? Where did they say this? I scoured the web and literary databases and can’t find anything which looks like it would fit this description. How are they allowed to make claims like this without a single source? There are more examples of this which are just as outrageous.
3) The labeling it prescribes is not useful.
The initiative explicitly says that is does not require the identification of which components were genetically engineered nor how they were engineered. The only plausible argument for labeling which I’ve heard thus far is that “If a health issue is ever found in a GMO product, the label will help us avoid them.” But that’s not true, any more than a “grown with pesticides” label would help deal with an issue attributed to a specific pesticide.
This is because every GMO (even using the narrow definition the initiative eventually establishes) is completely unlike every other. There is absolutely nothing in common between them. All it says is that some modification is made. There are dozens of unique modifications in widespread use today, and undoubtedly new ones will come in time. If you really want to “know what’s in your food,” you’ll at least need a label telling you what was modified and which modification(s) were used.
4) It’s full of exemptions with no justification for their inclusion.
The bill exempts animal products (such as dairy and meat/poultry) where the animal was fed or injected with GE food or drugs. It exempts cheese, yogurt, and baked goods using GE enzymes. It exempts wine (in fact, all alcoholic beverages). It exempts all ready-to-eat food, such as the hot food bars at PCC and Whole Foods. It exempts all “medical food” (without defining the term). Particularly odd for a bill which claims to be looking out for health concerns.
So who wrote this thing anyway?
The author of I-522 is Chris McManus, an advertising executive from Tacoma. When asked about the details of the bill, he told Seattle Weekly:
“Well, you know, I’m not a scientist. I work in media. Those kinds of questions I’ll have to defer to later in the campaign.” (source)
What does the science actually say?
My next task was to dig into actual scientific literature to see where the claimed health concerns were coming from, and to better understand the processes being used and research into their effects. Here’s what I found:
1) Currently marketed GMO products are safe
As the AMA, WHO, and others I linked to earlier called out, all research into existing GMO products has shown them to be as safe as their conventional counterparts. There have been zero cases of a health issue attributed to the presence of GMOs in food. (Source: Meta-study by Herman and Price)
2) Substantive equivalence is a useful tool
Government standards in the US and around the world require GMO products to establish “substantive equivalency” with their conventional counterparts and to identify and thoroughly test the effects of any deviation from this standard.
This is not to say that assessing the effects of GMOs is without challenges. However, researchers such as Harry Kuiper point out that many conventional foods contain some degree of toxic or carcinogenic chemicals and thus our existing diets have not been proven to be safe. This does mean that changes due to genetic modification could increase the presence of as-yet-unidentified natural toxins or anti-nutrients. However, this also means that positive changes can be missed just as easily. Bt Corn, for example, has been found to have lower levels of the fumonisins found in conventional corn (source).
More importantly, there is nothing anywhere to suggest that modern GMO techniques are more likely to result in such unintended and unidentifiable changes than traditional GE techniques or even “organic” cultivation. In fact…
3) Modern GMO techniques appear to be safer
More and more research is revealing that modern transgenic GMOs contain fewer unintended changes than result from traditional breeding and even environmental factors. (source, another source, another source).
Transgenics are GMOs produced by artificially transferring genes from a sexually incompatible species and tend to get the most attention from those objecting to genetic modification. Note that the term GMO also applies to cisgenic modifications (where the exact same methods are used to transfer genes from another of the same species or a sexually compatible one). I-522 makes no distinction between these concepts.
One reason GMO techniques appear to be safer is that they’re able to make more targeted changes. This illustration conveys a simplified view of these different GE methods:
Why do PCC and Whole Foods support I-522?
Because they’re businesses, and I-522 will make them more money. This poses an issue for fans of these “lifestyle” brands, because they generally associate them with good, wholesome values they share. However, these stores already sell largely non-GMO products. In fact, there are multiple certifications used throughout these stores which guarantee an absence of GMO material. These include USDA Organic and the Non-GMO Project (an organization who will provide a non-GMO label for products matching their standard in exchange for a fee).
Thus far I’ve stuck to pure facts with sources to back them up. If I may indulge myself in one paragraph of speculation, I will ask you to consider the list of exemptions included in I-522 and ask yourself where they came from. Then look at the products these stores sell which do not have opt-in organic certifications. I find it unlikely that the near complete overlap of these lists is an accident. However, this is just speculation on my part. If there is any hard evidence that the bill was crafted specifically such that these stores would experience no changes, I would be very interested in seeing it.
Whether done intentionally or not, though, the end result is the same. These stores will not have to change the products they offer, and because I-522 specifically calls out that USDA Organic and Non-GMO Project certified products require no additional scrutiny, their prices will not be affected. However, the same is obviously not true for their competitors like Safeway and QFC. These stores will see price increases.
Why would this cause prices to increase?
Farmers who already use non-GMO products, but who currently do not opt into a certification program, will have to pay for that program to avoid having a scary label added to their wares. That means they’ll have to increase prices. The large swath of producers who do use GMO products, or who are unable to guarantee their absence, will not only have to suffer sales effects from a misleading label, but will have to incur the costs of adding it. It’s difficult to say who will be hit harder, but the fact that this law will add cost to the system and thus result in higher prices is impossible to deny.
But why is it bad to know more about what we’re eating?
All else being equal, it’s not. But as I alluded to early in this post, the proposed label doesn’t tell you anything about what you’re eating, and all else is not equal. The spectrum of possible labels we could put on food to “inform” buyers is endless. We could put a label saying a food includes ingredients from crops which were sprayed with any kind of pesticide. We could label products made with unfiltered water (which will undoubtedly be lavished with support from Brita and Pur!). Hell, we could label products harvested using red tractors (no commie wheat!). But we don’t do these things because mandatory labels mean cost and bureaucracy. Regulation of the food industry is crucial to health and safety, but to be effective it must be based on science and facts, not emotional reactions. Support for I-522 seems to be largely based on what Stephen Colbert calls “truthiness.” While some things may feel right to your gut instinct, that doesn’t mean they are.
Where can I learn more?
The links embedded throughout this post provide a wealth of information about the subject. However, they barely scratch the surface. Some additional resources you may find useful include:
Biofortified (an independent educational non-profit from Wisconsin) provides a really great in-depth breakdown of I-522 and the associated controversy.
Wikipedia has a large page dedicated to the controversies around GMOs. It includes a lot of great summarization of the science and history of these issues, and is a great hub for finding references pertaining to all aspects of these issues.
There are numerous meta-studies which compile and assess the results of research spanning the peer-reviewed scientific literature. One example I linked to earlier is Herman and Price’s paper, Unintended Compositional Changes in Genetically Modified (GM) Crops: 20 Years of Research.